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    台灣食品自主管理體系與國外自主管理體系融合研究報告

    本會比對GFSI與台灣食品自主管理體系差異之處,發布台灣食品自主管理體系與國外自主管理體系融合研究報告,建構一致性且符合國際規範之食品自主管理系統,以提升製造商與通路商合作意願,降低供應鏈成本。

    TQF Products Certification Scheme Compliance with the Benchmarking Requirements of GFSI Version 7.1

    1. Introduction

    Since its establishment in 2000, GFSI has brought together stakeholders representing the global food industry to collaborate on advancing food safety.

    An essential part of that goal is to create a common and widely-accepted understanding of what constitutes a good food safety system. That is precisely what GFSI's Benchmarking Requirements have done. This tool has become the world's most widely accepted benchmark document for food safety requirements. 

    Within GFSI, benchmarking is a “procedure by which a food safety‐related certification program is compared to the GFSI Benchmarking Requirements”(GFSIBR). The process is designed to be executed in an independent, unbiased, technically proficient and transparent manner. A certification program is ‘recognized’ by GFSI when it has been verified that it meets internationally recognized food safety requirements laid out in the GFSIBR.

    Once successfully benchmarked against GFSIBR, Taiwan Quality Food Products Certification Scheme (TQFPCS) will achieve GFSI recognition, which lends a nameplate authority to these certifications and acts as a food safety passport of sorts throughout the global marketplace.  

    1. Compliance with GFSI Requirements Part I: The Benchmarking Process

    ​​​​Taiwan Quality Food Association (TQFA) is required to submit an application for recognition to GFSI together with the required supporting documents. During Mr. Bill McBride’s visit to TQFA’s office (August 7th to 9th, 2017), the internationalization group have filled the application form under his guidance. Required supporting evidence shall confirm that:

    • Taiwan Quality Food Association is a legal entity.
    • Taiwan Quality Food Association is not a Certification Body and shall not be governed or owned by one or more certification bodies.
    • There is an agreement with one or more Accreditation Bodies for Certification Bodies to operate to ISO/IEC 17065 or ISO /IEC 17021 for the scope of their Scheme.
    • Contractual relationships between TQFA and two Certification Bodies(CB) (i.e., Food Industry Research and Development Institute (FIRDI) and China Grain Products Research & Development Institute (CGPRDI)) that have accreditation for the scope of the TQFPCS with an Accreditation Body(AB) (i.e., Taiwan Accreditation Foundation, TAF)
    • TQFPCS has in place ten valid accredited certificates (for each relevant scope of the application) issued by Certification Bodies, including at least one valid certificate issued by each contracted Certification Body during a twelve-month period prior to the date of the application.
    • TQFPCS has been operational for a minimum period of twelve months prior to the date of application. During this period, certificates have been issued to a number of organizations. A Scheme is deemed to become operational on the date on which the first accredited certificate is issued by a Certification Body.
    • TQFPCS shall not be undergoing a significant change.
    • The Scheme shall not have any practices that are deemed as restricting access to markets.
    • The Scheme has undertaken a self-assessment to validate that the Scheme management and requirements are in compliance with the GFSI Benchmarking Requirements.

    Filling out the application form is not a difficult task. However, since the TQFPCS 2.0 has not been published yet, there are still questions that can’t be filled and supporting documents that can’t be provided. For example, the contract between TQFA and two certification bodies must be based on TQFPCS 2.0. Also, the minimum of ten certificates shall be the certificates accredited to TQFPCS 2.0. Furthermore, the change from TQFPCS 1.1 to TQFPCS 2.0 is considered a significance change, therefore, TQFA have to wait until the new version of TQFPCS is published, and have minimum 10 certifications, to be able to apply for GFSI. As for the requirement that a scheme must be operational for a minimum period of twelve months prior to application, Mr. McBride suggested this as a tricky situation. By stating that TQFPCS 1.0 have been running since 2015 and is updated to version 2.0, TQFA can still apply to GFSI Benchmarking event though TQFPCS2.0 have not been operational for twelve months.

    1. Compliance with GFSI Requirements Part II: The Management of Schemes

    GFSI Requirements Part II is part of the self-assessment task that TQFA have to take in order to successfully benchmark into GFSI. The objectives of Part II are to define:

    • The requirements for eligibility of a food safety scheme to be considered for benchmarking by GFSI,
    • The requirements for food safety scheme ownership and management,
    • The requirements for food safety scheme supporting systems,
    • The requirements for continuing recognition by GFSI, if recognition status is granted.

    The management of schemes is divided into ten sections. Below is the result of gap analysis conducted during Mr. McBride’s visit.

    1. Scheme Development and Maintenance

    Scheme development and maintenance requirements emphasize on TQFA as a scheme owner. TQFA is expected to be a legal entity, not owned or developed by a Certification Body.

    1. Integrity Program

    Based on the gap analysis conducted, compliance relating to the integrity program can be found in TQFPCS: Certification Body Management Procedure and TQFPCS: Certification Body Performance Evaluation Regulation. However TQFA must also establish office visits procedures of the witness audit; and/or witness audits to the CB, without relying to TAF.

    1. Relationship with Accreditation Bodies

    These requirements manage TQFA’s relationship with Accreditation Bodies (in this case: TAF). Based on the gap analysis, TQFA has full compliance to these requirements. The compliance to these clauses is contained in TQFPCS: Accreditation Body Management Procedure.

    1. Relationship with Certification Bodies

    TQFA’s management of Certification Body to ensure that it shall operate an effective and fully implemented quality system is contained in TQFPCS: Certification Body Management Procedure. As for other requirements in this section, the gap analysis showed that such compliance can also be found in TQFPCS: Accreditation Body Management Procedure (for requirements relating to the accreditation of CB by AB) and TQFPCS: Communication and Contact System (regarding the agreement from CB to notify TQFA in events of significance incident or non-conformities). Based on the gap analysis, TQFA still have to establish a clear management in the event that the range of certification services offered by a Certification Body are wider than those accredited.  

    1. Certification Body Personnel Competence General

    This section requires TQFA as the scheme owner to have an arrangement made with the CB in order for it to ensure its personnel competence. TQFA’s compliance to this section is contained in TQFPCS: Certification Body Management Procedure and TQFPCS: Regulations for the Application for Registration, Qualification Review and Service Fees of Professional Personnel.

    1. Auditor Competence Process Requirements

    Requirements for auditor competence are not published yet, and will be published in GFSI 7.2.

    1. Audit Program

    The management for TQFA’s audit program complies with GFSI’s requirements; except TQFA still have to establish a monitoring procedures to ensure that contracted Certification Bodies comply with the defined audit duration criteria and that appropriate actions are taken in the event that a Certification Body does not meet the defined requirements. Other compliance regarding audit frequency, audit duration, type of audits (announced or unannounced), etc. can be found in TQFPCS and TQFPCS Establishment and Revisions Regulations

    1. Audit Reporting

    For the requirements of audit reporting, TQFA still have to establish a monitoring system for audit time limit. Also, because during office visit, the GFSI team will check TQFA’s audit report, all reports must be well documented and translated to English. As for the system of generating and issuing audit report, TQFA’s compliance can be found in the TQFPCS.  

    1. The Management Certification

    In complying with the requirements under this clause, TQFA is suggested to strengthen its guidelines regarding conformity and non-conformity, also improve the management for CB in scoring conformities and non-conformities. Regardless of the gaps, other requirements in this section such as: a system for the granting, suspension and withdrawal of certification services by Certification Bodies for the scope of their scheme, are all contained in TQFPCS.

    1. Data Management

    TQFA is required to have a defined data management system. This is described in TQFPCS: Website Resources Management Procedure, where the data management system is clearly defined, which will help hold and maintain data for the effective management and operation of the scheme. As for the documentation of number of approved auditors, numbers of certificate issued and number of delisted are all accessible through the Information and Communication Technology (ICT) platform, currently managed by the Information Technology (IT) team.

    1. Compliance with GFSI Benchmarking Requirements Part III

    GFSI Benchmarking Requirements Part III is also part of the self-assessment. It is developed and published to specify the requirements for the recognition of food safety schemes. Since TQFA’s current plan is to benchmark into the EIV scope (Ambient stable products), this part is specified for EIV subcategory (although it is believed that the requirements for EI-EIV doesn’t differ much).

    The objectives of Part III are to define:

    • the requirements for the food safety management systems to be in place in the scheme’s standard for GFSI scope of recognition (in this case, EIV – Processing of Ambient Stable Products),
    • the requirements for the Good Practice requirements to be in place in the scheme’s standard for GFSI scope of recognition EIV – Processing of Ambient Stable Products ,  
    • the requirements for HACCP or HACCP based requirements to be in place in the scheme’s standard for GFSI scope of recognition EIV – Processing of Ambient Stable Products.

    TQFA’s scheme standard and other guidance documents shall provide sufficient detail to ensure that the Part III of GFSI requirements are met and that, within the benchmarking process, objective evidence of compliance can be found.  

    1. HACCP or Hazard Based Requirements (Section 1)

    The GFSI requirements for HACCP consisted of requirements for the standard (in this case: TQFPCS) to manage the HACCP system conducted by the supplier (in GFSI’s term: organization). GFSI requires the standard to be able to manage organization’s HACCP system in such manner that it is able to demonstrate an adequate food safety management system. This includes the ability to identify and control all food safety hazards (including allergens) also, capable of accommodating change. The Organization’s HACCP system shall also be defined per product/ product category and per process line/ process area. Clauses regarding HACCP requirements are contained in the TQFPCS version 2.0 Chapter 5. Based on the gap analysis that has been conducted, TQFPCS complied with all 4 standards of HACCP requirements.

    1. Food Safety Management Requirements (Section 2)

    The GFSI Food Safety Management Requirements is more elaborate than section 1. In this section, GFSI requires the standard to regulate the organization’s food safety management system. This section contains the regulations regarding food safety management in general, management responsibility and commitment, documentation, corrective action, etc. This section also regulates the requirements for food defense plan, food fraud mitigation plan and allergen management. The requirements for food defense and food fraud are new to this version of GFSI, and it is very important for these clauses to be included in TQFPCS version 2.0. Two clauses are introduced in GFSI version 7.1: purchasing from a non- approved supplier and food legislation. Both of these clauses are not included in the TQFPCS yet. Another gap in the TQFPCS is the management of allergen labelling. According to the gap analysis’s result, this section requires more attention, since there are many clauses that are still not completely covered by TQFPCS.   

    1. Good Industry Sector Practice Requirements (Section 3)

    The GFSI Good Industry Sector Practice Requirements is the GMP requirements that the standard shall have in order to control the organization. Based on the gap analysis that has been conducted, clauses in section 3 can be found in TQF General Provisions of Technical Specifications. Based on the result of the gap analysis, even though TQF General Provisions of Technical Specifications mostly comply with GFSI requirements; there are certain standards that need more elaboration. For example, regarding staff facilities, TQF General Provisions of Technical Specifications still lacks explanation about minimizing allergens risk in staff facilities. Clause about water quality and utility management (including ice) is also not mentioned yet in the TQF General Provisions of Technical Specifications

    1. Conclusion

    Conducting a gap analysis is very helpful in analyzing the shortcoming of TQFPCS standards and management system. Using the result of this gap analysis, it is easier for TQFA to pinpoint the standards that still need improvement in order to comply with GFSI benchmarking requirements. This gap analysis can be used as a tool in preparing TQFA confidently benchmark to GFSI in year 2018. As for the gaps that still need to be filled, action to modifying the TQFPCS can be done through studying other standards (e.g. BRC, SQF) and use their Food Safety Management Requirements as reference in improving TQFPCS.

    1. References  

    www.mygfsi.com

    
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